State Scheduled Tribe Commission lacks jurisdiction to verify caste certificates; power vests with Scrutiny Committees.

The petitioners, claiming to belong to the "Bhattra" Scheduled Tribe (ST) community, secured government employment based on caste certificates issued in 1993

Following complaints by private respondents (Respondents No. 7 and 8) alleging that the petitioners did not belong to the ST community, the Sub Divisional Officer (SDO) (Revenue), Gharghoda, conducted an inquiry and recommended the rejection of the complaint on 18.11.2022

Subsequently, the Chhattisgarh State Commission for Scheduled Tribes (Respondent No. 2) issued a notice to Petitioner No. 2 on 13.02.2024

the District Level Caste Certificate Scrutiny Committee (Respondent No. 3) issued another notice on 16.12.2025 for the production of documents

The petitioners challenged these proceedings, contending that the SDO’s report finalized the matter and that Respondent No. 2 lacked jurisdiction to issue such notices

Whether the Chhattisgarh State Commission for Scheduled Tribes has the legal authority to initiate proceedings or issue notices regarding the scrutiny and verification of caste certificates

Whether a recommendation by a Sub Divisional Officer (Revenue) precludes the District Level Caste Certificate Scrutiny Committee from exercising its statutory powers of verification

Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013 (referred to as "Act 2013")

Under Section 6 of the Act 2013, the District Level Caste Certificate Scrutiny Committee and the High Level Caste Certificate Scrutiny Committee are identified as the sole competent authorities to decide disputes and perform the scrutiny of social status certificates

The Court also recognized the principle that statutory commissions lack the inherent power to perform functions expressly reserved for specialized committees under specific social status legislation

The Court observed that while the State Scheduled Tribe Commission (Respondent No. 2) issued a notice based on a private complaint, it possesses no legal authority under the Act of 2013 to initiate or conduct caste verification proceedings

Consequently, the notice dated 13.02.2024 was found to be legally unsustainable

Conversely, regarding the notice issued by the District Level Caste Certificate Scrutiny Committee (Respondent No. 3), the Court held that this Committee is the legally designated authority under Section 6 of the Act 2013 to adjudicate caste disputes

The Court dismissed the petitioners’ argument that the SDO’s prior recommendation finalized the issue, noting that the SDO lacks the statutory authority to decide such disputes; that power is vested exclusively in the Scrutiny Committee

Therefore, the notice issued by Respondent No. 3 was held to be valid and required no judicial interference

However, the Court upheld the notice dated 16.12.2025 (Annexure-P/13) issued by the District Level Caste Certificate Scrutiny Committee, affirming its status as the competent authority under the Act 2013

The High Court partly allowed the writ petition and the petition was disposed of with no orders passed regarding Petitioner No. 1 as no specific notice against him was challenged in the record